ML20065D651

Responds to NRC 900816 Ltr Re Violations Noted in Insp Rept 50-285/90-32.Corrective Actions:Enhancements Made to Facility Mod Procedures & Engineering Instructions

ML20065D651
Person / Time
Site:	Fort Calhoun
Issue date:	09/17/1990
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-90-0745, LIC-90-745, NUDOCS 9009260064
Download: ML20065D651 (4)

Text

'

i l Omaha Public Power District 1 t

1623 Harney Omaha. Nebraska 68102 2247 402/536-4000 I

September 17, 1990 l LIC-90-0745 ],

l U. S. Nuclear Regulatory Commission i Attn: Document Control Desk Mail Station PI-137 Washington, DC 20555

References:

1. Docket No. 50-285

2. Letter from NRC (S. J. Collins) to OPPD (W. G. Gates) dated '

August 16, 1990

3. Letter from OPPD (W. G. Gates) to NRC (Document Control Desk) dated September 12, 1990 (LIC-90 0740)

Gentlemen:

SUBJECT:

Response to Notice of Violation - Inspection Report 50-285/90-32 Omaha Public Power District (OPPD) received the subject inspection report which identified one violation. The violation involved surveillance testing of emergency diesel generators (EDGs). Please find attached OPPD'; response to l the Notice of Violation in accordance with 10 CFR Part 2.201.

l In Reference 2, the NRC expressed concern that this violation is a result of inadequate corrective actions in response to a non-cited violation (NCV) identified in late 1989 (50 285/89-32). OPPD took corrective action to the l

subject NCV by revising the EDG surveillance tests to include the requirement l

for the verification of EDG loads during a refueling outage. However, OPPD incorrectly interpreted the Technical Specification limit.

OPPD's current program for verification and review of corrective actions is adequate and provides several checks to ensure that they are appropriate and timely. A currently established Safety Audit and Review Committee semi-annual i audit, assesses completed corrective actions on a random sample basis. No deficiencies have been identified in the past year in regards to corrective

/ I F 6A 9DO917 Q 9kCKcS00028 PDC 5

as su., '0I -

imnoum.m g u y one .

4b

~

,U. S. Nuclear Regulatory Commission LIC-90 0745  :

Page 2 actions taken in response to NRC violations. Inadequate corrective action taken for other findings are documented and properly hadressed. Therefore, this incident appears to be an isolated case and OPPD's program is adequate for ,

ensuring appropriate and timely corrective action. ,

If you should have any questions, please contact me.

Sincerely, W. G. Gates k Division Manager Nuclear Operations WGG/sel Attachment c: LeBoeuf, Lamb, Leiby & MacRae A. Bournia, NRC Project Manager R. D. Martin, NRC Regional Administrator, Region IV R. P. Mullikin, NRC Senior Resident inspector

?

?

E  ;

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION  ;

During an NRC inspection conducted June 17 through July 28 ad August 1,1990, i a violation of NRC requirements was identified. The violation involved surveillance testing of emergency diesel generators (EDGs). In accordance with .

the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 t CFR Part 2, Appendix C (1990) (Enforcement Policy), the violation is listed below:

Failure to Adeauntely Perform a Surveillance Test Technical Specification 3.7(1)c.iii states, " Tests shall be conducted during ,

each refueling outage to demonstrate the satisfactory overall automatic  !

operation of each diesel system. This test shall be conducted by verification ,

that emergency loads do not exceed the 2000 hr-KW rating of the engine."  !

Contrary to the above, the licensee failed, during the 1990 refueling outage, .

• to verify that emergency loads do not exceed the 2000 hr-KW rating of the EDG in that a load profile for emergency loads was not determined for the equipment when operating in an emergency condition.

This is a Severity Level IV violation. (Supplement 1) ,

P QPPD RESPONSE:

The Reason for the Violation. if Admitted 1.

OPPD admits to the violation as stated. The violation occurred as a result of an incorrect interpretation of the Technical Specification limit. OPPD interpreted the specification to mean a testing limit for the refueling outage automatic loading test.

2. The Corrective Steos That Have Been Taken and the Results Achieved t

OPPD has completed both an outside air temperature based engine / generator model and an update to the diesel generator LOCA loads model calculation.

An anaiysis (EA-FC-90-062) previously submitted for NRC information (Reference 3) demonstrates that the load profile for diesel generator DG 1 will be below the two thousand hour time / jacket water temperature based i output derating curve for outside ambient air temperatures of 107'F and below. Similarly the DG-2 load profile will be below the two thousand hour engine output curve for outside ambient temperature of 103*F and below.

Based on the above analyses / calculations, Fort Calhoun Station is considered in compliance with Technical Specification ,.7(1)c.iii which requires that autoconnected loads be within the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of each diesel generator, for an engine which is auto loaded starting from its pre-warmed temperature, t

l I

3. The corrective Steos Which Will Be Taken to Avoid further Violations

a. Enhancements will be made to OPPD's fort Calhoun Station modification i procedures and engineering instructions to provide more specific direction as to how to assess the impact of a new load on the diesel  !

generator. These enhancements will be made by October 28, 1990,

b. A surveillance test will be established with a refueling outage i frequency to verify that the expected worst case load profile for the  !

diesel generators as a result of a design basis accident (DBA) remains i below the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> diesel generator output limit based on ambient outside air temperature and jacket water outlet temperature. This '

will be in place by March 15, 1991. The next scheduled Fort Calhoun Station Refueling Outage will be conducted in the Fall of 1991. i

4. The Date When Full Comoliance Will Be Achieved I

OPPD will achieve full compliance by March 15, 1991.

1 l

l 1

- - - ,- - ~ ,-